Termination under § (c)(i); Whether abuse allegations constituted new or different grounds for termination; MCR 3.977(F)(1)(b); Hearsay; Domestic violence; Physical neglect; Housing; Employment; Parenting ability; Children’s best interests; Relative placement; Trauma-based bond

The court held that any evidentiary error related to new allegations was harmless, that § (c)(i) supported termination of respondent-mother’s parental rights, and that termination was in the children’s best interests. The trial court took jurisdiction after the children were found living in a tent without adequate clothing in 38-degree weather, and it later terminated the mother’s parental rights. On appeal, the court first rejected her claim that hearsay evidence about alleged pinching was inadmissible because it was related to the original grounds, including domestic violence and her ability to safely parent, so “legally admissible evidence regarding those grounds had already been introduced at adjudication.” Although sexual-abuse allegations presented a closer question, any error was harmless because the trial court did not rely on them for § (c)(i). The court next held that § (c)(i) was established because the mother failed to rectify domestic violence, physical neglect, housing, employment, and parenting barriers. It reasoned that she “failed to consistently participate in recommended services or show meaningful progress,” never progressed beyond supervised parenting time, lacked long-term housing, was unemployed, and minimized domestic violence. The court also found no reasonable likelihood of rectification within a reasonable time because she had not “accomplished meaningful change in the conditions that led to adjudication.” Finally, the court held that termination was in the children’s best interests because the mother’s parenting time produced safety concerns and negative behaviors, the bond appeared “trauma-based,” the children were strongly bonded to their relative placement, and that placement was meeting their extensive needs and was willing to adopt. Affirmed.